ML20236X036

Proposed Tech Specs Identifying That Provisions of Section 4.0.2.b Would Not Apply to Refuel Interval Surveillances

ML20236X036
Person / Time
Site:	LaSalle
Issue date:	12/04/1987
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20236X015	List: ML20236X014 ML20236X036
References
NUDOCS 8712080383
Download: ML20236X036 (10)

Text

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e y ATTACUMENT B-

, PROPOSED CHANGES TO_

THE TECHNICAL SPECIFICATIONS FOR OPERATING LICENSES NPF-ll AND NPP-18 e .

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' ' 'r ' ATTACHMENT _B_

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~ PROPOSED CHANGE". TO -1

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, , 1 THE TECHNICAL SPBCIFICATINS FOR- d l

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.OPEPATING LICENSES NPF-ll AND NPF-18 .

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FEVISED PAGES:

'. NPP-11 NPF-18

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-SURVEILLANCE REQUIREMENTS- I 1

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, 4.0.1 Surveillance Requirements shall_be met during the OPERATIONAL CONDITIONS .j -

or other conditions specified for individual Limiting Conditions for Operation 0 unless otherwise s,tated in an individual Surveillance Requirements.

4.0.2' Each Surveillance Requirement shall be performed within the specified l time interval .with: 1

a. A maximum allowable extension not to exceed 25% of the surveillance interval, but

b. The combined time interval for any 3 consecutive surveillance int: vals i shall not exceed 3.25 times the'specified surveillance interval. k .)

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4.0.3 Failure to perform a Surveillance Requirement within.the specified time 1 interval shall constitute a failure to meet the OPERABILITY requirements for a-Limiting Condition for Operation. Exceptions to these requirements are stated l

in the individual Specifications. Surveillance requirements do not have to be performed on inoperable eduipment.

l 4.0.4 Entry into an OPERATIONAL CONDITION or other specified condition shall not be made unless the Surveillance Requirement (s) associated with the Limiting ,

Condition for Operation have been performed witnin the stated surveillance  ;

j-interval or as otherwise specified.

4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2, & 3 components shall be applicable as follows:

a. Inservice inspection of ASME Code Class 1, 2, and 3 components and  !

inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief  ;

has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g) (6) (i).

b. Surveillance intervals specified.in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice l inspection and testing activities required by the ASME Boiler and i Pressure Vessel Code and applicable Addenda shall be applicable as follows in these Technical Specifications:

ASME Boiler and Pressure Vessel Rnquired frequencies I Code and applicable Addenda for performing inservice i terminology for inservice inspection and testing 1 inspection and testing activities activities j Weekly At least once per 7 days 1 Monthly At least once per 31 days l Quarterly or every 3 months At least once per 92 days Semiannually or every 6 months At least once per 184 days Every 9 months At least once per 276 days Yearly or annus11y At least once per 366 days l 1

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SURVEILLANCE REQUIREMENTS

4. 0.1 - Surveillance' Requireraents shall be met during' the OPERATIONAL CONDITIONS or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirements. 11 4.0.2 Each Surveillance Requirement shall be performed within the specified '

time interval with:

a. A maximum allowable extension not to exceed 25% of the surveillance interval, but

b. The combined time interval for any 3 consecutive surveillance intervals shall not exceed 3.25 times the specified surveillance interval. W  !

4.0.3' Failure to perform a Surveillance Requirement within the specified time interval shall constitute a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation. Exceptions to these requirements are stated

'in the individual Specifications. Surveillance requirements do not have to be performed on inoperable equipment.

4.0.4 Entry into an OPERATIONAL CONDITION or other specified t.ondition shall not be made unless the Surveillance Requirement (s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as otherwise specified.

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4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1,-2, & 3 components shall be applicable as follows:

a. Inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief a has been granted by the Commission pursuant to 10 CFR 50, Section \

50.55a(g) (6) (1).

b. Surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as j follows in these Technical Specifications: l ASME Boiler and Pressure Vessel Required frequencies Code and applicable Addenda for performing inservice terminology for inservice inspection and testing inspection and testing activities activities Weekly At least once per 7 days Monthly At least once per 31 days ,

Quarterly or every 3 months At least once per 92 days l Semiannually or every 6 months At least once per 184 days i Every 9 months At least once per 276 days v.

Yearly or annually At least once per 366 days LA SALLE - UNIT 1 3/4 0-2 l

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3.0.5 (Continued) 4 i

(as must be the components suppli.ed by the emergency power source) and all redundant systems, subsystems, trains, components and devices ~in the other division must be OPERABLE, or likewise satisfy Specification 3.0.5 (i.e. , be capable of performing their design functions and have an emergency power source OPERABLE). In other words, both emergency power sources 0 and 2A must ~i be OPERABLE and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE. If these conditions are not satisfied, action is required in accordance with this specification.

In OPERATIONAL CONDITION 4 or 5, Specification 3.0.5 is not, applicable, and thus the individual ACTION statement for each applicable Limiting' Condition for Operation in these OPERATIONAL CONDITIONS must be adhered to.  !

4 4.0.1 This specification provides that surveillance activities necessary J to ensure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL CONDITIONS or other conditions for which the Limiting Conditions for Operation'are applicable. Provisions for additional surveillance '

L activities to be performed without regard to the applicable OPERATIONAL CONDI-TIONS or other conditions are provided in the individual Surveillance Require-  !

ments. Surveillance Requirements for Special Test Exceptions need only be performed when the Special Test Exception is being utilized as an exception to an individual specification.

4.0.2 The provisions of this specification provide allowable tolerances f for performing surveillance activities beyond those specified in the nominal surveillance interval. These tolerances are necessary to provide operational flexibility because of scheduling and performance considerations. The phrase "at least" associated with a surveillance frequency does not negate this allowable tolerance; instead, it permits the more frequent performance of surveillance activities.

The tolerance values, tak; 1 either individually or consecutively over 3 test intervals, are sufficiently restrictive to ensure that the reliability associated with the surveillance activity is not significantly degraded beyond that obtained from the nominal specified interval.

HJ rNsear A-s 4.0.3 The provisions of this specification set forth the criteria for determination of compliance with the OPERABILITY requirements of the Limiting Conditions for ('peration. Under this criteria, equipment, systems or components are assumed to be OPERABLE if the asse:iated surveillance activities have been satisfactorily performed within the specified time interval. Nothing in this provision is to be construed as defining equipment, systems or components OPERABLE, when such items are found or known to be inoperable although still meeting the Surveillance Requirements. ,

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' APPLICABILITY BASES 3.0.5 (Continaed) ,

(as must be the ccmponents supplied by the emergency power source) and all a redundant systems, subsystems, trains, components and devices in the other division must be OPERABLE, or likewise satisfy Specification 3.0.5 (i.e., be capable of performing their design functions and have an emergency power i source OPERABLE). In other words, both emergency power sources 0 and 1A must  ;

t~e OPERABLE and all redundant systems, subsystems, trains, components and

' devices in both divisions must also be OPERABLE. If these conditions are not satisfied, action is required in accordance with this specification.

In OPERATIONAL CONDITION 4 or 5, Specification 3.0.5 is not applicable, and thus the individual ACTION statement for each applicable Limiting Condition for Operation in these OPERATIONAL CONDITIONS must be adhered to.

4.0.1 This specification provides that surveillance activities necessary i to ensure the Limiting Conditions for Operation are met and will be performed ,

during the OPERATIONAL CONDITIONS or other conditions for which the Limiting Conditions for Operation are applicable. Provisions for additional surveillance activities to be performed without regard to the applicable OPERATIONAL CONDI-TIONS or other conditions are provided in the individual Surveillance Require-  !

I ments. Surveillance Requirements for Special Test Exceptions need only be performed when the Special Test Exception is being utilized as an exception to an individual specification.

l 4.0.2 The provisions of this specification provide allowable tolerances for performing surveillance activities beyond those specified in the nominal surveillance interval. These tolerances are necessary to provide operational flexibility because of scheduling and performance considerations. The phrase "at least" associated with a surveillance frequency does not negate this allowable tolerance; instead, it permits the more frequent performance of surveillance activities.

The tolerance values, taken either individually or consecutively over 1 3 test intervals, are sufficiently restrictive to ensure that the reliability associated with the surveillance activity is not significantly degraded beyond that obtained from the nominal specified interval.

Add Enser A -v 4.0.3 The provisions of this r, specification set forth the criteria for determination of compliance with the OPERABILITY requirements of the Limiting Conditions for Operation. Under this criteria, equipment, systems or components are assemed to be OPERABLE if the associated surveillance activities have been satisfactorily performed within the specified time interval. Nothing in this i provision is to be construed as defining equipment, systems or components f OPERABLE, when such items are found or known to be inoperable although still meeting the Surveillance Requirements.

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The requirements of 4.0l2.b do~not-apply to refueling interval surveillance since the time interval between these surveillance is normally dictated by.the length of the scheduled fuel cycle, scheduled outages and forced outages. The length of time required for scheduled and forced outages

,can vary and may use significant portions of.the allowable extension while shutdown.

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ATTACHMENT C 1

SIGNIFICANT HAZARDS CONSIDERATION OPERATING LICENSES NPP-11 and NPf-188 1

J Commonwealth Edison has evaluated the proposed Technicel Specification Amendmeat-and determined that it does not represent a significant hazards consideration. Based on the criteria for defining a significant hazards consideration established in 10 CFR 50.92, operation of LaSalle County Station j

' Units 1 and 2 in accordance with the proposed amandment will not:

1) Invc1ve a significant increase in the probability or consequences of an {

accident previously evaluated because: J f

The 3.25' surveillance interval extension criteria of Technical j Specification t. 0.2 was not considered in the evaluation of the probability or severity of events analyzed in the Accident Analysis (UPSAR Chapter 15).

1 Additionally, the 18 month refuel interval was originally chosen to correspond to expected operating cycle length such that these surveillance would be performed during the bhutdown period. Since no basis can be determined for the 18 month interval other than conformance with expected operating cycle length, deleting the 3.25%

requirement does not involve a significant decrease in the effectiveness of the monitor'ing provision.

2) Create the possibility of a new or different kind of accident from any accident previously evaluated because:

The refuel surveillance interval will still be constrained by the maximum 1.25% interval extension criteria of Technical Specification 4.0.2.

3) Involve a significant reduction in a margin of safety because:

1 Deletion of the requirement "any three consecutive intervals must not i exceed 3.25 times the interval" from the refueling interval will not significantly effect equip- ment reliability. The current criteria allows a 22.5 month interval for as many as two intervals during a three interval period. Deletion of the 3,25 criteria will allow all three intervals to be 22.5 months long and provide consistency of operating cycles, per specification 4.0.2.a the Etaff has already i accepted that a 22.5 month interval will provide a sufficient level l I

of protection.

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Guidance has been provided in 51 FR 7744 (reference (b)), for the application of standards to license change' requests for determination of the existence of significant hazards considerations. This documents provides examples cf amendments which are and are not considered likely to involve significant hazards considerations. This proposed amendment does not involve a significant relaxation of the criteria used to establish safety limits, a significant relaxation of the bases for the limiting safety system settings or a significant relaxation of the bases for the limiting conditions for operations. Therefore, based on the guidance provided in the Federal Register and the criteria established in 10 CFR 50.92(e), the proposed change does not constitute a significant hazards consideration.

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Insert A Deletion of the requirement "any three consecutive intervals must not exceed 3.25 times the interval" will not significantly effect equipment reliability. The current criteria allows a 22.5 month interval for an many as two intervals during a three interval period. Delection of the 3.25 criteria will allow all three intervals to be 22.5 months long. per specification 4.0.2.a the staff has already accepted that a 22.5 month interval will provide a sufficient level of protection. Allowing this interval to be applied to all cycles will maintain a consistant level of protection.

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